Le v. The Queen, 2012 DTC 1297 [at at 3948], 2012 TCC 349 (Informal Procedure) -- summary under Subsection 163(2)

Favreau J. affirmed the Minister's net worth assessment of the taxpayer for $61,874 of unreported income in three years arising from a marijuana-growing operation, for which she had been convicted. Favreau J. noted that, as a "method of last resort," a net worth assessment is inherently "arbitrary and imprecise" (para. 17). Nevertheless, on the basis of the unreported income thus determined, he found that the magnitude of the failure to report income supported the Minister's assessment of gross negligence penalties.